​1. Purpose  
   1.1. The purpose of this Code of Ethics, Conduct & Responsibilities Policy (“Policy”) is to define and communicate the ethical standards, professional conduct expectations, and individual responsibilities that govern the behavior of all Red Queen Realty Group (“RQRG” or “the Company”) personnel. By adopting these standards, RQRG reaffirms its commitment to integrity, transparency, client-centric service, and compliance with all applicable laws and regulations.

 

2. Scope  
   2.1. This Policy applies to all employees, independent contractors, brokers, sales agents, interns, officers, and directors (collectively, “Personnel”) of Red Queen Realty Group in every office, division, and region in which the Company operates.  
   2.2. Third parties (e.g., vendors, consultants) who provide services under contract to RQRG must also adhere to those portions of this Policy that relate to conflicts of interest, confidentiality, and anti-corruption.  

 

3. Definitions  
   3.1. Confidential Information: Non-public business, client, financial, or proprietary data entrusted to RQRG or its Personnel.  
   3.2. Conflict of Interest: A situation in which personal, financial, or other interests could compromise, or appear to compromise, an individual’s judgement in performing RQRG duties.  
   3.3. Insider Information: Material, non-public information concerning a transaction, property listing or market condition that could influence the value of real estate or investment decisions.  
   3.4. Gift: Anything of value (e.g., cash, services, entertainment) offered to or received by Personnel from clients, vendors, or other third parties.  

 

4. Policy Guidelines & Requirements  
   4.1. Ethics & Integrity  
     4.1.1. Honesty and Accuracy: All representations—written, verbal, and electronic—must be truthful and complete. Misleading statements or omissions are prohibited.  
     4.1.2. Fair Dealing: Treat clients, colleagues, competitors and third parties with fairness, respect and courtesy. Discriminatory practices are strictly forbidden.  
     4.1.3. Accountability: Take responsibility for one’s actions and omissions. Promptly correct any mistakes.  

   4.2. Professional Conduct  
     4.2.1. Compliance with Laws: Adhere to all federal, state, and local real estate laws, regulations and licensing requirements—including fair housing, anti-trust, and anti-money laundering rules.  
     4.2.2. Confidentiality & Privacy: Safeguard client and Company confidential information, disclosing only to authorized parties and as required by law.  
     4.2.3. Conflicts of Interest:  
       • Disclose any actual or potential conflict to your manager or the Compliance Officer in writing prior to engaging in the related activity.  
       • Refrain from transactions that could impair objectivity or harm the Company’s reputation.  
     4.2.4. Gifts & Entertainment:  
       • Accept only modest gifts or entertainment that are customary, infrequent, and cannot be construed as an attempt to influence business decisions.  
       • Any gift over a nominal value ($100) must be disclosed and approved by the Compliance Officer.  
     4.2.5. Insider Trading & Confidential Listings:  
       • Do not trade on or disclose non-public, market-sensitive information.  
       • Adhere to the Company’s Listing Confidentiality Procedures (Section 5.3).  

   4.3. Responsibilities by Role  
     4.3.1. Senior Management:  
       • Lead by example; ensure resources for ethics training and compliance monitoring.  
       • Review and approve disclosures of conflicts or gift exceptions.  
     4.3.2. Supervisors & Brokers:  
       • Monitor team adherence; address violations promptly; document corrective actions.  
     4.3.3. All Personnel:  
       • Complete mandatory ethics and compliance training annually.  
       • Report suspected violations immediately.  

 

5. Procedures & Processes
   5.1. Reporting Violations  
     5.1.1. A confidential ethics violation report can be submitted via email at report@rqrealtygroup.com.  
     5.1.2. Reports may be made anonymously. RQRG prohibits retaliation against good-faith reporters.  
   5.2. Investigation & Resolution  
     5.2.1. The Compliance Officer will log and evaluate all reports within five (5) business days.  
     5.2.2. Investigations will be conducted impartially. Findings and corrective actions will be documented.  
   5.3. Listing Confidentiality  
     5.3.1. Access to off-market or pre-marketing listings is restricted to authorized Personnel.  
     5.3.2. All conversations and documents must be labeled “Confidential—Do Not Distribute.”  

 

6. Compliance Requirements & Consequences  
   6.1. Personnel must comply with this Policy and all related procedures.  
   6.2. Violations may result in disciplinary action, up to and including:  
     • Formal reprimand or counseling  
     • Suspension of licenses or access privileges  
     • Termination of employment or engagement  
     • Referral for civil or criminal prosecution  
   6.3. RQRG will cooperate fully with government or regulatory investigations.  

 

7. Disclaimers & Legal Considerations  
   7.1. This Policy does not create a contract and does not guarantee continued employment or engagement.  
   7.2. Nothing herein is intended to limit any other legal or regulatory obligations.  
   7.3. In the event of a conflict between this Policy and a binding law or regulation, the law or regulation will prevail.  

 

8. Company Culture & Tone
   8.1. At Red Queen Realty Group, we champion excellence, innovation, and unwavering integrity. Our clients trust us to navigate complex transactions—this trust is built on our collective commitment to ethical conduct and professional responsibility. We encourage open communication, continuous learning, and accountability at every level.  

 

 

9. Roles & Responsibilities Summary  
   • Compliance Officer: Policy custodian, investigator, advisor  
   • Human Resources: Training facilitator, record keeper, disciplinary partner  
   • Managers/Brokers: Day-to-day oversight, coaching, immediate corrective action  
   • Personnel: Ethical performance, timely reporting, policy adherence  

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